- Site: Transport Competent Authority
- IR number: 21-049
- Date: March 2022
- LC numbers: N/A
Executive summary
ONR regulates the civil transport of radioactive material by road, rail and inland waterway in Great Britain (GB). The ONR Transport Competent Authority (TCA) is responsible for delivering non-nuclear transport inspection and enforcement activities. This particular inspection forms part of that delivery function with reference to Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG), the Ionising Radiations Regulations 2017 (IRR17) and the Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR19). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ONR used ADR 2021 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Royal United Hospital Bath’s (RUH) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Combe Park site on 16 March 2022.
Interventions Carried Out by ONR
The chosen inspection sample included:
- notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- a suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- suitable and sufficient measures to restrict exposure – IRR17 Regulation 9;
- suitable and sufficient Contingency Planning and/or Emergency Arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1;
- adequate Transport Documentation – ADR 5.4;
- adequate Security arrangements – ADR 1.10;
- Equipment on Board – ADR 8.1.5.2; and
- a suitable and sufficient Management System – ADR 1.7.3.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by RUH for the safe transport of radioactive materials, including the associated arrangements for protecting workers against the effects of ionising radiations and reducing risks as low as reasonably practicable (ALARP).
The inspector compared relevant statutory requirements with both prescribed arrangements and actual practice. The inspector identified a number of examples of RUH meeting relevant good practice in reducing risk to levels that are ALARP, including having a transport RRA, contingency plan and overall implementation of legal requirements. Based on the inspection sample, the inspector initially judged the Radiation Risk Assessment (RRA) not to be suitable and sufficient. However, immediately after the inspection, RUH presented further documentation which satisfied the inspector that RUH had adequately assessed the risks.
During the inspection, the inspector suggested certain improvements to transport practices that would be prudent for RUH to consider.
Conclusion of Intervention
RUH demonstrated that its operations met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector did not identify any non-compliances with relevant legislation and suggested a number of improvements.
For this intervention, an overall IIS Rating of GREEN is given to reflect that Legal duties were complied with.